Decision (EU) 2025/1148 of the European Central Bank of 2 June 2025 amending Decision (EU) 2025/222 on access by non-bank payment service providers to Eurosystem central bank operated payment systems and central bank accounts (ECB/2025/2) (ECB/2025/18)

## Report on Amendments to Decision (EU) 2025/222 on Access by Non-bank Payment Service Providers to Eurosystem Payment Systems **1. Executive Summary:** This report analyzes Decision (EU) 2025/1148 of the European Central Bank (ECB), which amends Decision (EU) 2025/222 regarding access by non-bank payment service providers (NBPSPs) to Eurosystem central bank operated payment systems and central bank accounts. The core purpose of this amendment is to defer the date from which NBPSPs may request access to TARGET (Trans-European Automated Real-time Gross Settlement Express Transfer system) and to extend the transition period for NBPSPs migrating to TARGET. Key findings indicate that the amendments were necessitated by delays in some euro-area Member States transposing relevant directives into national legislation, and aims to avoid legal uncertainty and provide sufficient time for NBPSPs to migrate. **2. Introduction:** The purpose of this report is to provide an informative analysis of Decision (EU) 2025/1148, focusing on its amendments to Decision (EU) 2025/222. This analysis is based solely on the text of Decision (EU) 2025/1148. **3. Policy Overview:** * This report concerns an *amendment* to an existing policy: Decision (EU) 2025/222. * **Core Objective(s):** The overarching objective, as inferred from the text, is to facilitate the integration of NBPSPs into the Eurosystem payment infrastructure in a legally sound and technically feasible manner. The specific objectives of this amendment are to defer the date when NBPSPs can request access to TARGET and to extend the migration period for these providers. **4. Background and Rationale:** The reason for this specific amendment is linked to delays in some Euro-area Member States transposing Directives 98/26/EC and (EU) 2015/2366 into national legislation. The Governing Council of the ECB decided to postpone the amendments to the TARGET Guideline (EU 2022/912) to avoid legal uncertainty. This amendment to Decision (EU) 2025/222 is a direct consequence, ensuring consistency between the decision and the postponed TARGET Guideline amendments. The extension of the transition period addresses the practical need for NBPSPs to migrate effectively. **5. Key Provisions / Changes:** This section focuses specifically on the changes introduced by the amendment text (Decision (EU) 2025/1148) to Decision (EU) 2025/222: * **What specific part of the original policy is being changed:** The amendment directly modifies Article 22 and Article 34 of Decision (EU) 2025/222. * **What the *new* rule/provision *is*, based *only* on the amendment text:** * Article 22 of Decision (EU) 2025/222 is amended to replace the date "16 June 2025" with "6 October 2025". This means that the date from which NBPSPs may request access to TARGET is changed to October 6, 2025. * Article 34 of Decision (EU) 2025/222 is amended to replace the date "31 December 2025" with "31 March 2026". This extends the transition period for NBPSPs to migrate to TARGET until March 31, 2026. * **Explain the *difference* or the *effect* of this specific change:** * The effect of changing the date in Article 22 is to delay the point at which NBPSPs can officially request access to TARGET. This delay is intended to align with the application of the TARGET Guideline amendments. * The effect of changing the date in Article 34 is to provide NBPSPs with an additional three months to complete their migration to TARGET. This extension aims to ensure a smoother transition, acknowledging the technical complexities involved. **6. Target Audience and Stakeholders:** Based on the provided text, the primary target audience and stakeholders directly affected by these changes are: * **Non-bank payment service providers (NBPSPs):** Specifically, those seeking access to Eurosystem central bank operated payment systems, including TARGET. * **Eurosystem central banks:** As the operators of the payment systems and account providers. **7. Implementation Aspects (Inferred):** * **Responsible agency/bodies mentioned:** The European Central Bank (ECB) and its Governing Council are responsible for the decision and its implementation. * **Timelines or procedures specified:** The text specifies two key timelines: * The amended date of 6 October 2025, from which NBPSPs may request access to TARGET. * The extended transition period until 31 March 2026, for the migration of NBPSPs to TARGET. * **Implementation aspects related *specifically to the changes*:** NBPSPs that were planning to request access to TARGET on June 16, 2025, will now need to adjust their plans to align with the new date of October 6, 2025. Similarly, NBPSPs undergoing migration have an extended deadline until March 31, 2026, to complete the process. **8. Expected Outcomes / Impact of Changes:** The likely intended outcome of these specific changes introduced by the amendment text is to: * Ensure legal certainty by aligning the timeline for NBPSP access to TARGET with the implementation of the amended TARGET Guideline. * Provide NBPSPs with sufficient time to technically prepare for and complete their migration to TARGET, potentially avoiding disruptions to payment services. * Facilitate a more orderly and efficient integration of NBPSPs into the Eurosystem payment infrastructure. **9. Conclusion:** Decision (EU) 2025/1148 constitutes a tactical adjustment to Decision (EU) 2025/222, deferring the access date for NBPSPs to TARGET and extending the migration period. These amendments, driven by delays in national transposition of EU directives, aim to mitigate legal risks and provide NBPSPs with adequate time for a smooth transition. The changes are significant for NBPSPs seeking to participate in the Eurosystem payment infrastructure and highlight the complexities of harmonizing regulations across the Euro-area.

Key Entities Referenced